Making policies work

The European Union (EU) has committed to supporting the global transition to more sustainable food systems. As

the world’s largest food importer, the EU can use its trade policies and agreements to stimulate and incentivise more

sustainable practices by its trade partners. In this brief, we provide specific recommendations on how the EU can do so.

Building on lessons from existing initiatives, the EU should adopt sector-specific regulations and sustainability standards

to promote imports of sustainable food, and restrict the import of illegally or unsustainably manufactured products.

Further, real change can only be achieved if the EU makes sustainable food systems an explicit objective of its free trade

agreements, negotiates relevant sustainability provisions in these agreements and monitors efficiently the impact of

these provisions on food systems. At the multilateral level, the World Trade Organization and the upcoming 2021 Food

Systems Summit can be good platforms for the EU to build alliances with like-minded countries to push for global trade

rules that promote sustainable food systems.

To be effective, these efforts need to be based on a good understanding of the various ways trade affects food systems.

They also need to be based on inclusive consultation involving potentially marginalised food systems actors and civil

society representatives, and to be complemented by other relevant policies, including on investment and development

cooperation.

Lead authors: Francesco Rampa, Olivier de Schutter, Sean Woolfrey, Nick Jacobs, San Bilal, Jeske van Seters, Emile Frison

October 2020

EU trade policy for sustainable food systems

SUSTAINABLEFOOD SYSTEMS

BRIEFING NOTE

1

Introduction

Our food systems produce large volumes of food, but

they also contribute to land and water degradation,

threaten biodiversity and generate greenhouse gas

emissions, malnutrition and livelihood stresses for

farmers. There is growing recognition in Europe and

beyond that food systems need to become more

environmentally sustainable and resilient, more

inclusive of poor and marginalised populations, and

better able to deliver healthy and nutritious diets to all.

Through the European Green Deal and Farm to Fork

Strategy (F2F), the European Union (EU) has committed

to a more economically, socially and environmentally

sustainable European food system, and to use its

external policies to promote sustainable food systems

beyond its borders.

In this context, the International Panel of Experts on

Sustainable Food Systems (IPES-Food) and the

European Centre for Development Policy Management

(ECDPM) are collaborating to advance dialogue on the

role of EU external policies in promoting a transition to

sustainable food systems globally.1 Supporting this

transition requires a range of tools and approaches in

different policy areas. Nonetheless, trade policies can

and should serve as important means to promoting

sustainable food systems. As the largest importer of

food products, the EU is particularly well placed to use

its trade policies and agreements to stimulate and

incentivise more sustainable practices by its trade

partners. The European Commission’s ongoing review

of EU trade policy provides a perfect opportunity to

explore how to do so.

In this brief we provide recommendations on general

principles that can help ensure EU trade policy is better

able to promote sustainable food systems, and

sustainable development more broadly. We also

provide recommendations on the use of specific

unilateral, bilateral and multilateral trade policy tools

1 Sustainable food systems should provide and promote affordable, safe and nutritious food for all current and future populations in a manner that has a neutral or positive impact on the natural environment and preserves and restores its ecosystem services, is robust and resilient (especially to the effects of climate change), generates fair economic returns - including for small farmers - and is socially acceptable and inclusive. SAPEA, Science Advice for Policy by European Academies. (2020). A sustainable food system for the European Union. Berlin.

and processes for these ends. These recommendations

represent IPES-FOOD and ECDPM’s joint submission to

the EU trade policy review.

Principles for using trade policy to promote sustainable food systems

Sustainable and resilient food systems that support

livelihoods, provide sufficient healthy food for all,

protect biodiversity and the environment and

contribute to social equity are crucial for achieving a

number of Sustainable Development Goals (SDGs),

particularly SDGs 1, 2, 3, 8, 12, 13 and 15. An EU trade

policy that promotes and supports a global transition

towards more sustainable and resilient food systems

would therefore make a great contribution to

sustainable development. To promote and support

such a transition, EU trade policy should be guided by

the following four principles.

Policy coherence for sustainable food systems and

sustainable development. The interaction of European

trade and non-trade policies generate trade-offs

and/or synergies in terms of their impact on food

systems globally. Policy coherence can help mitigate

negative trade-offs and exploit synergies. The EU

should seek to ensure policy coherence for sustainable

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2

development (PCSD) and for sustainable food systems

between: (i) its trade and non-trade policies (including

internal policies); (ii) its trade policy instruments and

approaches at the unilateral, bilateral and multilateral

levels; (iii) EU and EU member state policies; and (iv) its

policies towards partner states and the interests and

capabilities of those states. EU trade policies,

development cooperation (including aid for trade) and

public financing instruments for stimulating private

investment should be used in a coherent and

complementary way to support economic and

agricultural transformation pathways that enhance

food system sustainability.

Gradual and progressively ambitious implementation

of new approaches. New and innovative approaches to

using trade policy to promote economic, social and

environmental sustainability are needed. Unilateral,

bilateral and multilateral policies, regulations,

negotiations and agreements offer different pathways

for such approaches. Where new approaches may face

resistance from other countries, the EU should consider

using unilateral measures to pilot such approaches and

demonstrate ‘proof of concept’. Lessons should then

be drawn for scaling these up to and mainstreaming the

approach in bilateral agreements. Building on coalitions

of the willing, the EU should also seek to foster open

plurilateral agreements in multilateral fora, notably at

the World Trade Organization (WTO). Similarly, where

certain partners are willing to cooperate on new

approaches in e.g. specific sectors or commodities, the

EU should pursue such targeted arrangements (see

more below), while exploring opportunities to expand

these approaches to other sectors, commodities and

partner countries, or to plurilateral and multilateral

frameworks.

2 “Through its external policies, including international cooperation and trade policy, the EU will pursue the development of Green Alliances on sustainable food systems with all its partners in bilateral, regional and multilateral fora”.

3 the F2F and other EU traceability policies already envisage the use of “sustainability food labelling frameworks” to facilitate consumer choice (also within collaborations with third countries)

Inclusive consultation and partnership building for

implementation. EU trade policies should be based on

inclusive multi-stakeholder processes and promoted

through partnerships and dialogue, including via multi-

country and multi-stakeholder 'Green Alliances', in line

with the commitments of the Farm to Fork Strategy.2

These processes should build ownership of the design,

implementation and monitoring of trade policy and

related non-trade policies and accompanying

measures.

Sustainability as an explicit goal. Given the increasing

urgency of promoting sustainability as an overarching

policy objective, and consistent with article 3(5) of the

Treaty on the Functioning of the EU, the EU should

define sustainability as an explicit objective of its trade

and other external policies and refer to this in its trade

agreements. Putting this principle into practice to

support sustainable food systems will require efforts to

differentiate between trade in sustainable food

products and trade in non-sustainable food products.

While this is not a straightforward exercise, and is

subject to certain disciplines under WTO agreements,

progress can be made through the use of standards,

certification and traceability schemes,3 through

targeted subsidies linked to sustainability criteria, and

through unilateral trade measures (see below).

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3

Sector-specific initiatives and trade preferences for sustainable imports

The EU should explore sector-specific cooperation

agreements to ensure that imports entering the EU

have been legally and sustainably produced (for

example, working towards zero deforestation, zero

child labour, zero biodiversity loss, carbon neutrality)

in line with relevant international commitments and

standards, including those deriving from UN human

rights treaties and ILO conventions, and adhering to

the same level of sustainability requirements as EU

producers. In doing so, it should draw lessons from, and

build on, the cocoa sustainability standards being

developed with Cote d’Ivoire and Ghana, and the

broader precedent of Voluntary Partnership

Agreements (VPAs) under the Forest Law Enforcement,

Governance and Trade (FLEGT) Action Plan. These

approaches should focus initially on ‘forest risk

commodities’ and/or supply chains dominated by a

small number of exporting countries. In a second

phase, the EU should ensure application of these

sustainability standards beyond the targeted

commodity, i.e. progressively apply the new

enforcement capacities and cooperation tools to the

whole of a country’s agricultural sector, so it becomes

a licensed ‘sustainable food supplier’, while working

with importing companies to fast-track the application

of new horizontal due diligence requirements in the

agricultural sector.

The EU should explore preferential trade frameworks

that differentiate between products based on

whether or not they are sustainably produced and

distributed, and/or on their impact on consumer

nutrition and health. Such frameworks could either

make preferences conditional on food products

meeting relevant sustainability criteria, or provide

additional preferences for those food products that

do. While it is sometimes questioned whether such

differentiation is compatible with non-discrimination

clauses in trade agreements, including the GATT and

GATS agreements of the WTO, these agreements in fact

4 See UNFSS 4th Flagship Report “Scaling up Voluntary Sustainability Standards through Sustainable Public Procurement and Trade Policy”, September 2020. https://unfss.org/home/flagship-publication/

5 For instance, EU-Japan FTA states in Art 19 that "The Parties recognise that promoting trade in agricultural products and foods between them is in their mutual interest, and aim at promoting cooperation on sustainable agriculture, including rural development

provide some flexibility in this regard, provided the

differentiation on sustainability grounds is not a source

of unjustified discrimination and does not entail

disproportionate impacts on trade. The F2F and EU

traceability policies already envisage the use of

“sustainability food labelling frameworks” to facilitate

consumer choice (also based on collaboration with

third countries). This differentiation, to be further

defined also in line with available evidence (such as the

recent UNFSS Report4 mapping how free trade

agreements that include sustainability standards can

support countries' SDG ambitions) could be an

important tool to support a global move towards

sustainable food systems. The EU should seek to

introduce such differentiation on sustainability grounds

in its revised General Scheme of Preferences Plus

(GSP+) and in its free trade agreements (FTAs). Where

the introduction of sustainability criteria for

differentiation creates difficulties for producers from

developing countries to access European markets

under its preferential trade frameworks, the EU should

use its development cooperation instruments, such as

aid for trade (AfT), to support those producers, and

other relevant food value chain actors, to meet these

criteria and to shift to more sustainable practices.

Using free trade agreements to promote sustainable food systems

While the promotion of sustainable food systems will

rely heavily on action in other policy areas (e.g.

investment policies, agricultural policies, development

cooperation), the EU should ensure that its bilateral

trade agreements support sustainable production,

consumption, investment and trade to the extent

possible. This can be best achieved by:

1. Including the promotion of sustainable food

systems as an explicit objective of EU FTAs and

stipulating in FTA texts the principle that the

parties commit to cooperation on sustainable food

systems;5

4

2. Including other provisions to promote

sustainable food systems in EU FTAs (including

beyond Trade and Sustainable Development

Chapters6), with these provisions being in line with

internationally accepted sustainability

frameworks, and subject to multi-stakeholder

consultation, notably through enhanced Domestic

Advisory Groups (DAGs) and joint dialogues7;

3. In line with the commitment in F2F to develop

'Green Alliances',8 strengthening multi-

stakeholder consultation and participation in

the negotiation, implementation and

monitoring of the sustainability-related

provisions of EU FTAs to address the current

limitations of DAGs and joint civil society

meetings (i.e. the functioning of civil society

mechanisms incorporated in EU FTAs) and

better ensure that the sustainability concerns of

diverse food system stakeholders (including

peasant farmers and grassroots and community-

based civil society groups) are addressed;

4. Providing adequate support for FTA

implementation (e.g. via AfT, investment

promotion and private sector engagement),

including building capacity for SMEs and

smallholder farmers to meet relevant

sustainability standards and participate in

sustainable food trade and sustainable food

value chains;

5. Ensuring that monitoring and evaluation of EU

FTAs covers their impact on the sustainability

of food systems in the EU and in the partner

country or region.

When using sustainable food labelling frameworks and

international sustainability standards to maximise the

contribution of trade policy to sustainability, the EU

should ensure it takes into account the level of

development of partner countries and seek to build

local ownership with a view to reach agreements with

partners based on an ‘equal partnership’ spirit and

based on the corresponding standards/frameworks as

agreed in international fora like the Committee on

and the exchange of technical information and best practices for providing safe and high quality foods for consumers in the European Union and Japan". Based on this approach, useful text could be added relative to F2F and SFS.

6 F2F: “The EU will seek to ensure that there is an ambitious sustainability chapter in all EU bilateral trade agreements” 7 See for instance Ashraf, N. and J. van Seters (2020), Recommendations to strengthen civil society engagement in EU trade

agreements, ECDPM Briefing Note 119, September. https://ecdpm.org/bn119 8 F2F: “Through its external policies, including international cooperation and trade policy, the EU will pursue the development of Green

Alliances on sustainable food systems with all its partners in bilateral, regional and multilateral fora”.

World Food Security (CFS).

The EU can also use its sustainability impact

assessments (SIAs) more effectively to ensure its FTAs

promote food system sustainability, in particular by:

1. Integrating food system sustainability

considerations into SIAs for all EU FTAs and

including more systematic and detailed

treatment of all relevant aspects of food system

sustainability (including in relation to climate

resilience, biodiversity, gender equality, health

and nutrition, food safety, etc) likely to be

affected by trade liberalisation;

2. Updating the official EU SIA Guidance

Handbook with more explicit guidance for

assessing food system sustainability impacts;

3. Ensuring SIAs are sufficiently inclusive and

participatory, by involving potentially affected

food systems actors in partner countries;

4. Tailoring models used for SIAs, and their

assumptions and specifications, to include food

system sustainability criteria, and addressing the

limitation of equilibrium models assuming full

employment as the starting point; and

5. Improving ex-post assessment of the impact of

FTAs on EU and partner country food system

sustainability, informing corrective action if

necessary.

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5

Growing sustainable trade with neighbouring countries and Africa

In order to strengthen the sustainable dimensions of

its trade and investment relations with neighbouring

countries and Africa, the EU should:

1. Provide aid for (sustainable food) trade that

focuses on building the capacity of

neighbouring and African countries to produce

and trade ‘sustainable’ (food) products,

particularly those with existing or potential

markets in Europe, drawing on lessons from EU

member states like the Netherlands, and its

Centre for the Promotion of Imports from

Developing Countries (CBI);

2. Promote development (blended) finance to

stimulate private investment in the food

systems of neighbouring and African countries,

in particular to generate opportunities for

investments that are likely to have large positive

impacts on food system sustainability to

become commercially viable over time, paying

special attention to impacts on smallholder

farmers and food SMEs, drawing on the

resources of the European Fund for Sustainable

Development (EFSD/EFSD+), and its Investment

Window on Sustainable Agriculture, Rural

Entrepreneurs and Agribusiness,9 and ensuring

that EU-supported investments via financial

institutions are aligned with these principles;

and

3. Stimulate private sector engagement around

food system sustainability objectives, including

through EU-Neighbourhood and EU-Africa

sustainable business platforms like the

Sustainable Business for Africa Platform (SB4A)

and the AU-EU Agribusiness Platform, and

through stimulating partnerships and business-

to-business interactions and experience sharing,

9 As in the current EFSD investment window, and as recommended by the EU Task Force Rural Africa (2019): https://ec.europa.eu/info/sites/info/files/food-farming-fisheries/farming/documents/report-tfra_mar2019_en.pdf

10 See for instance Seters, J. van and S. Bilal (2020), Sustainable EU business and trade: How the Enterprise Europe Network can promote trade beyond Europe, ECDPM Briefing Note 115, March. https://ecdpm.org/bn115

11 “Through its external policies, including international cooperation and trade policy, the EU will pursue the development of Green Alliances on sustainable food systems with all its partners in bilateral, regional and multilateral fora”

drawing lessons from successful European

mechanisms.10

Strengthening multilateral governance for sustainable food trade

In pursuing WTO reform, the EU should seek to ensure

that promoting sustainable food systems becomes a

more central goal of the multilateral trading system.

The EU can contribute to this objective by:

1. Exploring in line with F2F,11 the establishment

of a voluntary, inclusive and transparent

‘Green Alliance’ at the WTO with like-minded

members from the global North and South,

based on shared sustainability ambitions and

involving civil society from all members, and

together establishing a WTO Working Group to

examine how WTO agreements and rules can

contribute to more sustainable food systems,

possibly as an outcome of the 2021 Food System

Summit;

2. Using this Green Alliance and Working Group to

push for updating the WTO ‘Green Box’ to

accommodate domestic subsidies for

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6

sustainability and resilience objectives based

on clear and transparent criteria, while still

remaining committed to reducing trade-

distorting agricultural subsidies, and for building

support for a new approach to WTO agriculture

negotiations that puts sustainability and

resilience at the centre of the agricultural trade

agenda;

3. Providing unilateral assurances (via a

declaration) that the EU will not launch WTO

disputes against countries making use of Green

Box subsidies for sustainability and resilience

objectives;

4. Championing open plurilateral approaches (as

in the case of the Environmental Goods

Agreement) and sectoral approaches to address

specific sustainability challenges or solutions

(e.g. green public procurement), with those

WTO members willing to undertake deeper

commitments towards sustainability;

5. Promoting greater coordination between the

WTO and global ‘food and agriculture’

institutions around trade and sustainable food

systems, including by using platforms and

events like the Committee on World Food

Security (CFS) and the 2021 Food Systems

Summit to institutionalise regular inter-agency

engagement at the highest level (WTO DG, FAO

DG, CFS Chair), identify areas of collaboration,

task divide effectively and improve policy

coherence12; and

6. Formulating a coherent message on the

importance and role of trade policy to address

climate change and promote sustainable

development, and bringing this to all relevant

high-level processes culminating in the 2021

summits: Climate Adaptation Summit, Nutrition

for Growth Summit, COP26, COP15 of the

Convention on Biological Diversity, and Food

Systems Summit.

12 For further details and discussion about this proposal, see for instance Rampa, Dekeyser, Alders and Dar, ECDPM-Chatham House paper, December 2019 https://ecdpm.org/publications/global-institutional-landscape-food-agriculture-achieve-sdg-2/

Conclusion

Drawing on insights from a range of trade and food

systems experts, this brief has presented

recommendations on: (i) principles that can help

ensure EU trade promotes sustainable food systems

beyond EU borders and (ii) specific trade instruments,

approaches and fora that the EU can and should use to

promote sustainable food systems. IPES-Food and

ECDPM are grateful to have the opportunity to provide

these recommendations as input to the European

Commission’s public consultation on the review of EU

trade policy, and we hope that the EU is willing and able

to take up these recommendations. In the meantime

IPES-Food and ECDPM will continue to collaborate on

the role of EU trade and other external policies in

promoting a transition to sustainable food systems

globally.

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About IPES-Food

The International Panel of Experts on Sustainable Food Systems (IPES-Food) seeks to inform debates on food systems

reform through policy-oriented research and direct engagement with policy processes around the world. The expert

panel brings together environmental scientists, development economists, nutritionists, agronomists, and sociologists,

as well as experienced practitioners from civil society and social movements. The panel is co-chaired by Olivier De

Schutter, former UN Special Rapporteur on the Right to Food, and Olivia Yambi, nutritionist and former UNICEF

representative to Kenya.

www.ipes-food.org

About ECDPM

The European Centre for Development Policy Management (ECDPM) is an independent ‘think and do tank’ working on international cooperation and development policy in Europe and Africa.

Since 1986 our staff members provide research and analysis, advice and practical support to policymakers and practitioners across Europe and Africa – to make policies work for sustainable and inclusive global development.

Our main areas of work include:• European external affairs• African institutions• Security and resilience• Migration• Sustainable food systems• Finance, trade and investment• Regional integration• Private sector engagement

For more information please visit www.ecdpm.org

This publication benefits from the structural support by ECDPM’s institutional partners: The Netherlands, Belgium, Estonia, Finland, Ireland, Luxembourg, Sweden, Switzerland, Denmark and Austria.

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